Dangerous Goods Code Review Opens Use of Curtain Systems

From April 1 this year, dangerous goods carriers will have the choice of using either gates or curtain systems, so long as they form part of a load restraint system that complies with national heavy vehicle regulations.

Key Takeaways: 

• The Competent Authorities Panel (CAP) has approved use a certified load restraint curtain (CLRC) system for securing dangerous as well as the use of rated gates
• Where rated gates are used, they must comply with the load restraint guide, meaning that:
  1. No dangerous goods protrude above the sides or gates by over 30 per cent of the height of the article or package
  2. No parts of an article or package may protrude horizontally beyond the sides or gates
  3. The dangerous goods are stowed and restrained to ensure the rated capacity of the gates isn’t exceeded.
• Another key amendment requires for ‘emergency information’ to be carried on any vehicle transporting a dangerous goods.
• New guidelines also allow the use of portable tanks with shells made of fibre-reinforced plastics (FRP) materials for transporting dangerous goods.

Dangerous goods carriers will be able to use a certified load restraint curtain (CLRC) system under amendments to the Australian Code for the Transport of Dangerous Goods (ADG) by Road & Rail which take effect from April 1, 2023.

Load Restraint Systems

Clause 8.1.3 of the current ADG Code (7.7) specifies the use of metal gates when transporting a placard load of unpackaged dangerous articles or dangerous goods in packages in a curtain-sided vehicle.

Under a biennial update, which included a full comparison of provisions in the Code against the source wording in the UN Model Regulations (UN MR) to identify translation and other discrepancies that have occurred over time, the Competent Authorities Panel (CAP) - whose prime responsibility is to consider submissions requesting exemptions, determinations and classifications that may operate at variance to ADG 7.7 – have approved a request for one exemption from 8.1.3 where a CLRC system is used.

Over the last two decades there’s been considerable improvements to truck safety, and the approval recognises significant advancements load restraint methodologies and legislative requirements since this requirement was first written, in particular the introduction of CLRC systems.

CLRC systems are tested and certified to provide load restraint meeting the performance standards specified in the Heavy Vehicle (Mass, Dimension & Loading) National Regulations. A rated CLRC system, when used as specified in the certification, provides the same protection as a similarly rated gate.

In fact, the NTC notes, the requirement for gates in 8.1.3 provides no qualification that the gates must be rated or that the load must not exceed that rating. Nor does it specify that the gates must form part of a complete load restraint methodology or system.

As such, the blanket requirements for gates could be seen as potentially providing an inferior level of safety, the NTC suggests.

What’s more, National Transport Commission’s (NTC) Manager Legislative Maintenance Debra Kirk adds that gates also pose other health and safety risks.

She cites Australian Trucking Association (ATA) estimates that the weight of gates on a vehicle is around 300kg; and that in 2015-16, musculoskeletal injuries accounted for 63 per cent of serious injuries in the trucking industry.

As such, 8.1.3.2 of the Code has been amended to: allow the use of either rated gates or a CLRC system.

Where rated gates are used, they must form part of a complete load restraint system that complies with the load restraint guide.

The guide mandates that no dangerous article or package containing dangerous goods protrudes above the sides or gates by over 30 per cent of the height of the article or package; that no parts of an article or package may protrude horizontally beyond the sides or gates; and the dangerous goods are stowed and restrained to ensure the rated capacity of the gates isn’t exceeded.

Emergency Information Must Be Carried

Another key amendment to the Code relates to the requirement for ‘emergency information’ to be carried on any vehicle transporting a placard load of dangerous goods.

The ADG Code currently defines ‘emergency information’ as the Dangerous Goods - Initial Emergency Response Guide, published by Standards Australia (HB:76).

However, the NTC notes the most recent version of the guide was published in 2010, making it extremely outdated and misaligned to current emergency procedures.

In response, in 2019 the CAP approved the Australian Emergency Response Guide Book (AERG2018) for use as emergency information under the ADG Code.

Based on the CANUTEC 2016 Emergency Response Guidebook developed jointly by Transport Canada, the US Department of Transport, and the Secretariat of Transport and Communications of Mexico, the definition of ‘emergency information’ in the ADG Code has been amended to reflect the shift to the ANZ-ERG.

Additionally, a process has been established to ensure the AERG is amended each time CANUTEC is updated. Since AERG2018 was first approved and published, CAUNTEC has published an updated 2020 guidebook.

The ANZ-ERG is free to download and can also be purchased in hard copy from Canprint at a cost of around $20 per copy. This compares to an approximate cost of $110 per copy for the HB:76. HB:76 is also tightly copyright controlled and no part is permitted to be replicated without written permission.

Kirk adds that provision has also been made to allow for the use of individual Emergency Procedure Guides (EPG).

EPGs for the more common substances transported as a single load will be prepared by a CAP working party and made free to download from the NTC website.

A blank template EPG, with instructions, will also be free to download, allowing duty holders to prepare their own substance specific EPGs.

Fibre Reinforced Polymer Portable Tanks

ADG 7.8 also introduces an entirely new chapter allowing for the use of portable tanks with shells made of fibre-reinforced plastics (FRP) materials.

Previously, Kirk points out, the Code required the use of metallic tanks due to concerns about FRP breaking down.

The new chapter specifies the requirements for the design, construction, inspection, and testing of portable tanks constructed from FRP.

Effective Dates

ADG 7.8 is effective April 1, 2023, and mandatory from April 1, 2024. The commencement date in some states may be later than 1 April 2023, please check with your competent authority.

The updated Code can be downloaded here.